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QUESTION:

OSHA recently announced a program to improve the quality of MSDSs. What can I do to make sure that the MSDSs my employees use are accurate, complete and easy to understand?

ANSWERS:

Limit your liability

First and foremost, it is the responsibility of chemical manufacturers to make sure that MSDSs are accurate, complete and to some degree, easy-to-understand... although the last part is somewhat open to interpretation. As an employer, if you notice something on an MSDS that appears to be incomplete, inaccurate or confusing, we recommend that you contact your supplier or the manufacturer immediately and review your concerns. If there is something inaccurate or missing, the manufacturer is obligated by law to correct the error.

OSHA and other standards-setting organizations like ANSI encourage chemical manufacturers to make MSDSs easier to read and navigate. For instance, ANSI recommends a 16-part MSDS that has a standard style format specified by ANSI Z4001-1993.

As a user of chemical products, there are a number of things you should be doing to limit your risk exposure and potential liability:

• Review your MSDSs periodically to make sure they are up-to-date, complete and legible. Make certain your MSDSs are easily accessible to your employees.
• Train your employees on how to find and read an MSDS.
• Work with your suppliers to make sure they provide you with easy-to-read, up-to-date, complete and accurate MSDSs in a timely fashion. If you can receive and distribute your MSDSs electronically — all the better.
• You may create “summary sheets” of MSDSs to highlight the hazards of specific chemicals. But it’s important to point out that if you edit, augment or change an MSDS, you may become liable for the content of that MSDS. Consider using an electronic system or Web-based MSDS service to help you access, manage and deploy your MSDSs more efficiently.

Glenn Trout, MSDSonline

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Document delivery is essential

Does a tree that falls unheard in the forest make a sound? Even if an MSDS is written in the clearest language and organized in the best manner, a system for document delivery to the right employees in a timely fashion from a centralized MSDS library is essential.

Formatting MSDSs into high-quality Adobe Acrobat (PDF) digital files is now common practice and ensures optimum readability when printed — especially when compared to faxes and copies. Software solutions keep these documents readily available 24/7 online. Access by employees and emergency personnel using a common Web browser such as Internet Explorer is now second nature to most, and with the appropriate interface, employees should have no trouble quickly finding the documents they need to ensure safe use of the chemicals in their workspace.

With MSDS software and a central MSDS library, a limited amount of information about each MSDS on file is keyed into the system and used for indexing and reporting purposes. The actual MSDS can be scanned into the system, or users can download a PDF or simply reference its URL link when building an MSDS record.

Search buttons within the software help users quickly find vendor sites and MSDSs on the Internet by using any of the entered indexing information. Once an MSDS has been located in a search, its image can be viewed on the computer screen and/or printed out.

A word about adding special information to the MSDS record: A user with add/edit MSDS record access can also enter local product names into the system so that employees can search by familiar names. Other kinds of MSDS record information can be included to clarify safety in handling and usage. However, this does require knowledgeable access by an industrial hygienist or safety manager who must be able to properly interpret the original MSDS.

Jim Runde, President, ImageTrak

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Beyond compliance

Presuming that new chemical compounds with unique chemical hazards are not created in the processes performed within a place of business, OSHA places legal responsibility for the accuracy and completeness of MSDS entirely upon the manufacturer or other responsible party that created the original manufacturer’s MSDS.

But many employers are rightfully concerned that inaccurate or incomplete MSDSs may impact the safety of their employees. In addition, language barriers or MSDSs prepared without consideration of the informational needs of the intended audience (those filled with technical jargon) can limit the value of MSDSs regardless of their degree of completeness.

Quality control: Prudent employers review the MSDS portion of their hazard communication programs to determine if they truly satisfy the intent of hazard communication. That is, do all manufacturers’ MSDSs for the hazardous materials on their inventory clearly communicate the hazard characteristics of those materials, and do they address preventative measures, personal protective equipment, and first aid adequately to empower employees to protect themselves effectively?

This review can be labor-intensive and requires scrutiny with a substantial level of chemical safety expertise. For this reason, proactive firms may choose to outsource MSDS evaluation to an EHS or hazmat outsource provider who has an entire staff of knowledgeable professionals whose core competencies are related to chemical safety and hazardous materials information management.

Control of the process can be maintained through contract-specified review criteria, and professional health and safety outsource providers may provide hotline access to safety professionals in order to aid employees in interpretation of difficult MSDSs. Manufacturers with inadequate MSDS can then be contacted, and revised MSDSs requested. Few manufacturers will fail to respond should their MSDS contain errors or omissions that could result in OSHA compliance action should their inaction result in agency notification.

Language assistance: Though OSHA mandates that all MSDS be in English, the hazard communication standard also requires that employee information be communicated to employees such that they “know how to obtain and use information on labels and MSDS.” For non-English literate employees, a method must be employed to communicate the MSDS information in a manner readily understandable to them.

Probably the most effective method to deal with this issue is to provide a trained bilingual employee on each relevant shift to provide MSDS information upon request or to have all relevant MSDS translated. Since MSDS terminology is technical in nature, it’s important to work through a translation service knowledgeable in health and safety terminology if translation is the solution of choice. Again, this would be a tall order for many organizations, so a sensible alternative is to contract with an outsourced provider who provides a 24-7-365 hotline, including language line assistance for non-English speaking employees.

Proactive employers recognize that excellence in a health and safety program cannot be supported by inadequate MSDS data communication. Hazard communication programs can be reviewed to identify such failures, and internal or outsource solutions can be identified to correct deficiencies before they lead to employee accidents or exposures. In doing so, proactive companies go well beyond the specific requirements of OSHA’s hazard communication standard and achieve its intent.

Michael Beckel, Supervisor, Training, 3E Company

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Audit for accuracy

First, the MSDS inventory needs to be audited for accuracy and completeness. Many hardcopy MSDSs are either unreadable or missing pages/information due to photocopying, faxing, hole-punching or just aging.

Second, MSDSs found to be lacking information need a current replacement. A system should be put in place to “tag for current replacement” those MSDSs that employees encounter lacking information.

Third, an electronic system is more desirable than hardcopy. PDFs at face value can appear a good option, but can contain data integrity problems as described above. Electronic text is the best option for utilizing the rich data of the MSDS — constituent information and for maintaining accuracy and completeness.

Fourth, increased use of concise standard phrases will help maintain and enhance the understandability of MSDS information.

David Lochridge, General Manager, Production, Dolphin Software

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If you are developing MSDSs…

1) Use one standard format.

2) If there is no information for a specific section — enter N/A, don’t remove the section from the form.

3) Create a margin that will allow for fax lines — this will allow for printed copies to stay legible when shared with others.

4) Clearly mark the Manufacturer, Product Name and Revision Date on the MSDS.

5) If a product name has changed from one version to another, add a “Formerly known as” line.

6) Include full ingredient data: chemical name, CAS #, percentage of product (use range if you want to keep actual formula a secret), etc.

7) Verify all CAS #s before calling it complete — register at www.chemfinder.com or other such Web sites for verification.

8) Include full data: units of measure for all physical data, not just the number (amount). Example: Density = 4…. 4 what? Lbs/gal, gm/L, etc.

9) Clearly specify the product’s physical state: Solid, Liquid, or Gas — the person reviewing the MSDS may not always have the actual product in front of them to know what the product actually is.

Jody DeChristopher, Account Manager, Dolphin Software

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Categorization is the future

It has been reported that almost 90 percent of MSDSs currently in use are inaccurate, and the technical format in which most are published stretch even the most highly educated toxicologist’s capacity to understand how to use them. Put a night shift environmental services worker in a hospital where a container of gluteraldehyde just spilled and watch chaos ensue as he tries to identify what to do next.

Categorization is the future of hazardous chemical management. Rather than archiving thousands of individual MSDSs in countless binders, chemicals can be categorized into a specific number of groups and hazard levels with the same hazards and spill responses, making for a more accountable program.

Each category can identify physical and health hazards, as well as suggest interventions in the case of a spill, injury or fire. Employees can be trained more efficiently, the risks of long-term chemical exposure can be better managed, and the safety staff can spend more time on what they were hired to do.

Effective categorization promotes a level of accuracy, comprehensiveness and simplicity in chemical management that the MSDS alone simply cannot.

Karan Singh, Ph.D., Chief Scientific Officer, MC Technologies